Reminder to Submit Comments on the CY 2026 PFS Proposed Rule Policy Changes for Quality Payment Program by 9/12/2025

The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP).

The Notice of Proposed Rulemaking (NPRM) includes proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Specifically, we’re proposing policies that:

• Continue the transformation of MIPS through MIPS Value Pathways (MVPs).
• Are responsive to feedback and concerns raised by interested parties.
• Maintain stability within the MIPS program through the established performance threshold.

2026 Policy Proposal Highlights

Key QPP policies that we are proposing in the CY 2026 PFS Proposed Rule include:

• Introducing 6 new MVPs for the 2026 performance year that are related to diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery.
• Introducing a 2-year informational-only feedback period for new cost measures, allowing clinicians to receive feedback on their score(s) and find opportunities to improve performance before a new cost measure affects their MIPS final score.
• Maintaining the current performance threshold policies, leaving the performance threshold set at 75 points through the 2028 performance year.
• Introducing Qualifying APM Participant (QP) determinations at the individual level, in addition to existing determinations at the APM entity level.

Overview of RFIs

We are also seeking feedback on RFIs about the following topics:

• Establishing Core Elements for MVPs, to require reporting on key quality measures within each MVP.
• Establishing a process to assign clinicians to an MVP, to facilitate the most relevant reporting for their scope of care.
• Transitioning to FHIR-based electronic clinical quality measure (eCQM) reporting in quality reporting programs.
• Understanding the current environment, including challenges, with collecting and exchanging high-quality healthcare data.
• Changing requirements for the Query of Prescription Drug Monitoring Program (PDMP) Measure and Performance-Based Measures in the Public Health and Clinical Data Exchange Objective.